In organizations that serve vulnerable populations — from healthcare facilities to schools, churches, and nonprofits — your mission depends on trust and safety. For hiring and volunteer managers, this often means navigating two different screening standards. How do you maintain due diligence while juggling varied policies and complex risk profiles?
The path forward requires cohesion by defining one standard of safety for screening volunteers vs. employees. The challenge is applying a single policy of care when the needs of the two groups are so distinct, and when the actual scope of necessary safety checks must align directly with the role’s responsibility.
This guide provides the essential best practices for scoping, frequency, and maintaining safety standards across volunteer and employee screening. You’ll learn exactly how to apply a consistent screening policy across both volunteer and employee background checks while maintaining compliance and safety.
Disclaimer: This is not intended to be legal advice. It is always best practice to consult your legal counsel to determine your organization’s screening and compliance requirements.
The first best practice for managing volunteer and employee background checks is accepting that when you use a third-party screening company, the federal screening process remains identical for everyone, regardless of whether they are paid or unpaid.
While the volunteer role is rooted in mission, the screening process is rooted in federal law designed to protect the individual’s rights. Consistency eliminates liability that stems from treating volunteers more casually than paid staff. Your organization must adhere to three core legal requirements for all individuals (employees, contractors, and volunteers):
Before running any background check, you must secure the candidate’s permission. For screening in the U.S., this means providing a clear, separate disclosure form that outlines your intent to screen. The consent must be explicit and signed before you proceed. Skipping this step for volunteers is one of the quickest ways to face class-action litigation over the Fair Credit Reporting Act (FCRA).
If a background check reveals information that leads you to deny placement — even if it's a volunteer position — you cannot simply say "no" and move on. You must follow the three-step Adverse Action process for all personnel:
Note: While the FCRA sets the federal minimum, many state and local jurisdictions impose additional requirements for the Adverse Action process. These may include a longer waiting period, specific mandated forms, or rules regarding how far back you can consider criminal history. Always verify state and local requirements based on the applicant's residence and the job location.
Beyond the FCRA's procedural requirements, you must also comply with the Equal Employment Opportunity Commission (EEOC) guidance, which prohibits using blanket policies to disqualify applicants based on criminal history. This is essential to preventing claims of unfair, discriminatory hiring practices.
The biggest operational error organizations make is running a basic or “lighter” package for volunteers just because they are unpaid. The court system views risk based on job duties and access, not compensation.
Best practice is to move away from default employee or volunteer packages and adopt a role-based risk policy. This ensures your organization (and those it serves) are protected and that your screening is legally defensible.
Your screening policy should categorize roles into tiers based on three factors: access to vulnerable populations, access to organizational assets, and level of supervision.
| Risk Tier | Role Examples | Background Check Considerations |
| High | Youth Mentor, Home Healthcare Aide, Volunteer Treasurer | Employment/Education Verification, Credit Check (if fiduciary), National Criminal Search, Sex Offender Registry, SSN Trace and Basic Identity Check, and Abuse Registry Searches |
| Medium | Supervised Event Helper, Front Desk Admin, Staff Driver, Part-Time Office Assistant, Seasonal Camp Counselor | MVR Checks (if applicable), Employment Verification, National Criminal Search, Sex Offender Registry, SSN Trace and Basic Identity Check |
| Low | One-Time Event Volunteer, Office Mail Sorter (no PII access), Remote Data Entry Contractor (no PII) | Employment Verification, SSN Trace and Basic Identity Check, National Criminal Search, Sex Offender Registry |
Your highest-risk roles require the same core safety checks regardless of whether you issue paychecks. The goal of the matrix is to clarify that the additional checks for paid staff (i.e., Employment Verifications or Credit Checks) are about competence and fiduciary trust, while the core checks for volunteers are non-negotiable standards of safety.
Selecting the right checks for every position is one of the biggest operational challenges employee and volunteer managers face. You can simplify this process immediately by using our free, interactive Employment Screening Calculator. Simply input your industry and the job role you’re hiring for, and receive a list of relevant checks to consider.
The greatest liability for organizations serving vulnerable populations is failure to perform the checks required by local and industry regulatory bodies. While the FCRA sets the bar, state and niche industry mandates define the content of the background checks. Screening volunteers vs. employees requires strict adherence to both.
Standard criminal background checks only access court records. They do not automatically include state-mandated registries for abuse or neglect. If your personnel work with children, seniors, or disabled individuals, Abuse Registry Searches are critical.
A single check at the start of employment (or volunteer term) is not sufficient for long-term safety. The "reasonable care" standard extends throughout the person's tenure:
For organizations operating in regulated industries, there are additional, mandatory searches required that eliminate individuals prohibited from receiving federal funding or practicing in that field.
The Office of Inspector General (OIG) and System for Award Management (SAM) lists identify individuals excluded from participating in Medicare, Medicaid, and other federal programs. Any hospital, clinic, or auxiliary volunteer who handles patient contact or claims must be screened against these lists.
Managing the complexity of legal standards (FCRA, EEOC, and state mandates) and multiple screening tiers requires more than a manual or fragmented process. You need technology that enhances your policy. Prioritize the following features in your background screening solution:
Your platform should allow you to configure and save specific packages (e.g., "High-Risk Volunteer Tier," "Paid Finance Staff Tier"). This prevents staff from accidentally ordering the wrong level of check and guarantees consistency across all locations and managers.
Your background screening technology should provide tools to initiate and manage the Adverse Action process in a single workflow. This helps reduce manual errors and legal risk.
All screening results, consent forms, and adverse action documentation should be centralized and time-stamped (ideally in your chosen ATS or CRM). This creates a legally defensible audit trail and protects you against negligent hiring claims.
Protecting children, seniors, and clients is too important to be compromised by an inconsistent screening policy. For hiring and volunteer managers, the time spent juggling separate volunteer and employee standards is time taken away from recruiting talent, managing staff, and focusing on your mission.
The ultimate best practice is recognizing that you don't have to manage this complexity alone. Consistency is the best safeguard, and achieving it requires a single, unified system that enforces your policy without fail.
Verified First partners with organizations like yours to take the administrative burden off your team. This means you access:
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